Notice at Collection

Epoch Investment Partners, Inc. ("TD Epoch") collects certain categories of personal information from you when you submit it to us through various features on our website.  For more information about our online practices, including those regarding our website, please view our Online Privacy Code.

For California Consumers: TD Epoch (herein "we", "us", and "our") also collects your personal information if you have a financial product or service managed by TD Epoch, or you have discussed your interest in a product or service offered by TD Epoch. We then use this information for business, commercial, and regulatory compliance purposes. Please refer to the tab below entitled "California Consumer Privacy Act" ("CCPA") to view the categories of personal information we collect, the purposes for which it is collected or used, and whether the information is sold or shared. In this tab, you can also find more information about your rights regarding your personal information, under the heading "Your CCPA Rights."

When you visit our website, we do not sell your personal information to a third party or share your personal information with a third party for cross-context behavioral advertising.

Please scroll down to view the California Consumer Privacy Act tab for an explanation of your rights regarding your personal information.

TD Epoch - California Consumer Privacy Act Policy

 

Financial institutions collect personal information necessary to offer and provide financial products and services, as well as permitted by federal, state, and local law. TD Epoch collects personal information to use for various business purposes, including but not limited to:

  • Operational Purposes. Includes offering and providing financial products and services, processing and fulfilling payments and other transactions, and to service existing or prospective accounts, products and service offerings.
  • Security and Fraud Detection. Includes verifying client’s identities; detecting security incidents; protecting against malicious, deceptive, fraudulent or illegal activity; and supporting prosecution of such activity.
  • Marketing and Data Analytics. This includes advertising and marketing initiatives and services, data analytics and quality assurance reviews.
  • Internet and Web Interaction. Please see our Online Privacy Code for a detailed explanation on the data collected when you interact with any of our electronic communications.
  • Legal and Regulatory Obligations. Includes collection, disclosure, and storage of data necessary to comply with statutory or regulatory requirements.
  • Other notified purposes. For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

The categories of personal information that TD Epoch has collected in the preceding 12 months include:

  • Identifiers. This includes, but is not limited to, personal identifiers such as name, alias, address, social security number, passport number, e-mail address, Internet Protocol address and other online identifiers, and other similar identifiers.
  • Personal Information Covered Under California’s Customer Records Law. This can include data that is also covered under other categories. Personal information in this category can include financial information, driver’s license or state identification card number, or employment.
  • Protected Class Characteristics. Includes information about race, color, religion or creed, national origin, sex, age, disability, veteran status, genetic information, and citizenship status.
  • Internet or Other Electronic Network Activity Information. Includes browsing and search history, and interactions with our website.
  • Geolocation Data.
  • Professional or Employment Information.
  • Inferences. Insights that we may use to build a profile about you; includes profiles, preferences, and behaviors drawn from collection and analytics of any of the other categories of personal information collected.
  • Sensitive personal information. This can include data that is covered under other categories described above. Personal information in this category can include social security number, driver’s license or state identification number, race or national origin, and login information.

The sources from which TD Epoch collects this personal information include, but are not limited to:

  • The client or their authorized parties or agents. Authorized parties or agents includes, but is not limited to, parties such as client-directed third-parties or institutions representing client/prospective clients, attorneys, guardians, and those with powers of attorney.
  • **Affiliates
  • Service providers
  • Government agencies
  • Our website
  • Data analytics providers

The business or commercial purposes for which TD Epoch may disclose your personal information include, but are not limited to:

  • For all of the stated purposes above for which TD Epoch may collect personal information.
  • Auditing Purposes. Related to our interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with those specifications and other standards.
  • Debugging/Repair Activity. Debugging to identify and repair errors that impair, or may impair, existing system and application functionality.
  • Short-term transient use for our purposes.
  • For services performed on our behalf by a service provider performing services on behalf of a business for which TD Epoch is a service provider. Includes, but is not limited to, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, advertising, marketing, or analytic services, or providing such similar services on behalf of a business or service provider.
  • Client information, or analytic services, or providing such similar services on behalf of a business or service provider.

The categories of third parties with whom TD Epoch may disclose personal information, and the categories of personal information that may be disclosed with such third parties include, but are not limited to:

  • The client or their authorized agents or parties: Personal information categories include: Identifiers, Customer records law, protected class characteristics, commercial information.
  • Affiliates and subsidiaries: All categories of personal information collected.
  • Service providers, which include nonaffiliated entities providing operating systems, platforms and other services to support day-to-day operations: All categories of personal information collected.
  • Government, regulatory, or legal authorities: Any categories of personal information collected can be disclosed that is subject to legal process or proceedings.

TD Epoch has established information retention guidelines that define consistent minimum standards and requirements for the length of time information and records are to be maintained. Standards and procedures will also be in place to mandate the suspension of ordinary disposition and destruction processes as necessary, and to comply with preservation obligations related to actual or reasonably anticipated litigation, regulatory requirements, supervisory investigation or audit.

TD Epoch has not sold or shared personal information in the preceding 12 months. TD Epoch does not sell or share personal information of minors under 16 years of age. Under CCPA, a “sale” means the disclosure of personal information to a third party for monetary or other valuable consideration. “Share” or "Sharing" when used in this policy has the meaning of the term in the CCPA: the disclosure of personal information to a third party for cross-contextual behavioral advertising, whether or not for monetary or other valuable consideration. TD Epoch does not use or disclose “sensitive personal information” for purposes which would require us to offer clients the right to limit under the CCPA.

Personal information does not include:

  • Publicly available information. “Publicly available information” means: information that is lawfully made available from federal, state, or local government records or information TD Epoch has a reasonable basis to believe is lawfully made available to the general public by a client or from widely distributed media, or by the client; or information made available by a person to whom the client has disclosed the information if the client has not restricted the information to a specific audience;
  • Truthful information that is a matter of public concern;
  • Client information that is deidentified or aggregate, as those terms are defined by the CCPA; and
  • Information otherwise exempt from the CCPA, such as personal information collected, processed, sold, or disclosed subject to the federal Gramm-Leach-Bliley Act and implementing regulations.

** Our affiliates include those companies that control, are controlled by or under common control with TD Bank US Holding Company or The Toronto-Dominion Bank, such as other banks, financial companies, registered broker dealers, investment advisors, and insurance agencies.

The California Consumer Privacy Act (CCPA) provides California residents rights regarding the collection and use of their personal information, subject to certain exceptions. An authorized party may submit requests on your behalf by following the instructions below and attaching a written authorization signed by the resident. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf.

Generally, California residents have the following rights:

  • Right to Know and Access. To request a disclosure of the categories of personal information that have been collected; the categories of sources from which the information was collected; the business or commercial purpose for collecting, selling, or sharing the personal information; the categories of third parties to whom the business discloses personal information; and access to the specific personal information the business has collected about the consumer in a portable format.
  • Right to Request Deletion of Personal Information. To request that a business delete personal information that the business has collected from the consumer, subject to certain exceptions provided under the CCPA.
  • Right to Correct Inaccurate Personal Information. To request that a business correct any inaccurate personal information that the business maintains about the consumer.
  • Right to Opt-Out of the Sale of Personal Information or Sharing of Personal Information for Cross-Context Behavioral Advertising. As stated above, TD Epoch does not sell or share personal information for cross-context behavioral advertising.
  • Right of No Retaliation Following Opt-Out or Exercise of Other Rights. To not be denied a product or service, charged a different price or rate, denied a discount or other benefit because the consumer exercised any of his/her rights under the CCPA.

If you would like to exercise any of your rights, please click on the "Make a Privacy Request" tab on our website and use one of the outlined contact methods to submit the request to us. To process your request, you will be asked to provide information about yourself. TD Epoch will use this information to verify your identity. This will include basic contact information (first name, last name, phone number, e-mail) or additional information we may require to sufficiently verify your identity. This information will not be further disclosed or retained for longer than necessary for purposes of verification, or used for unrelated purposes.  

Only California residents can make a request. A California resident is a person who is in California for a purpose that is not temporary or transitory, or is domiciled in California but is outside of the state for a temporary or transitory purpose. If you are not a resident of California, you can view our Online Privacy Code webpage on our website to learn more about our privacy practices.

Here's what you can request:

  • Access to a portable copy of your personal information and transparency about our processing of your personal information
  • To delete your personal information
  • To correct your personal information
  • If you are a current customer or employee and would like to update your information

 

Here's how you can make a request:

Phone: 1-866-963-4654

Online Request Form

Make a request

Here's what you'll need:

  • Contact Information (first name, last name, phone number, and e-mail address)

Why do you need to provide this information?

To process your verified consumer request(s), TD Epoch requires certain information from you to verify your identity. TD Epoch will use this information only to verify your identity and will store the information for that purpose. This information will not be further disclosed or retained for longer than necessary for purposes of verification, or used for unrelated purposes. If we cannot verify your identity, we are not obligated to fulfill your request.

What you will receive

  • Request to Know and Access
    Consistent with applicable law, you will receive a portable copy of any personal information TD Epoch has collected on you during the 12 months immediately preceding your request. This will include any information provided in your CCPA request form. You may submit a request no more than two times in a 12-month period; this period begins upon your first submission of the request form.
  • Request to Delete
    Consistent with applicable law, we will delete your information upon request request unless an exception applies.
  • Request to Correct
    Consistent with applicable law, we will correct your information upon request.

 

Contact Us

 

If you have questions about TD Epoch's California Consumer Privacy Act Policy or practices, please call us at 1-866-963-4654

Who does CCPA apply to?

CCPA applies to California residents only. For purposes of CCPA, a California resident is a person who is in California for a purpose that is not temporary or transitory or is domiciled in California but is outside of the state for a temporary or transitory purpose. The rights described above do not apply to residents of other U.S. states or persons who reside outside of the United States.

What doesn't the CCPA apply to?

There are certain activities, information, and circumstances involving the collection, use, processing, sale, or disclosure of personal information that are exempt or excluded from CCPA. CCPA exemptions and exclusions include, but are not limited to:

Personal information collected or sold if every aspect of the commercial transaction takes place wholly outside of California.

Deidentified or aggregate consumer information.

GLBA: The CCPA does not apply to personal information collected, processed, sold or disclosed subject to Gramm-Leach-Bliley Act and its implementing regulations (GLBA). GLBA is the federal law that regulates the collection, disclosure, and safeguarding of individuals' nonpublic personal information who obtain financial products or services primarily for personal, family, or household purposes from a financial institution. For example, if you are a California resident and you have a personal financial product with us, such as a personal credit card, the CCPA rights do not apply to the personal information associated with that account. There are other types of personal information that are not covered by the rights and limitations in the CCPA.

Fair Credit Reporting Act: CCPA does not apply to any activity involving the collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on an individual's credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency, user or furnisher of consumer reports as defined under the Fair Credit Reporting Act.

What can I expect if I exercise any of my rights?

Request to Know

Consistent with applicable, law, you will receive a response to your verified request within 45 days of submission, unless we notify you prior to the end of those 45 days that the delivery date of the response will be extended by an additional 45 days. Along with the response to the verified request, you will receive a copy of certain information TD has collected on you during the 12 months immediately preceding the date of your verified request. This will include any information provided in your verified consumer request form. TD is not obligated to provide a response more than twice in a 12-month period; this period begins upon your first submission of the verified consumer request.

Request to Correct

You will receive a confirmation of your correction request within 45 days of submission, unless we notify you prior to the 45 days that the delivery date of confirmation will be extended by an additional 45 days. Consistent with applicable law, we will correct your information at your request.

Deletion Request

You will receive a response to your verified request within 45 days of submission, unless we notify you prior to the end of those 45 days that the delivery date of the response will be extended by an additional 45 days. Consistent with applicable law, we will delete your personal information in response to your request.

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